A.M. No. 10-4-19-SC, March 7, 2017
Re: Letter of Tony Q. Valenciano, Holding of Religious Rituals at the Hall of Justice Building in Quezon City

FACTS

Tony Q. Valenciano wrote to the Chief Justice alleging that the basement of the Quezon City Hall of Justice had been converted into a Roman Catholic chapel, complete with religious icons and an organ, where daily noon masses were held. He contended this violated the constitutional separation of Church and State and the prohibition against using public property for the benefit of any religion. He detailed resulting inconveniences: disturbance from choir rehearsals, obstruction of the basement as a public resting area, blocked access to lavatories for employees and litigants during mass, internal strife among employees vying for liturgical roles, and water supply cuts because a generator was turned off for silence.
The matter was referred to the Office of the Court Administrator (OCA) and the local Executive Judges for comment. The judges acknowledged the masses but reported implementing mitigating measures, such as shortening the duration, ensuring pathways to restrooms remained accessible, and clarifying that utility interruptions were due to maintenance, not the religious activity. They argued the use was merely incidental and temporary, not a permanent appropriation for religious purposes.

ISSUE

Whether the holding of Catholic masses within the Quezon City Hall of Justice violates the constitutional principles of separation of Church and State and the non-establishment of religion.

RULING

The Court, speaking through Justice Mendoza, held that the practice, as conducted, was constitutionally permissible but must be strictly regulated to avoid any appearance of state preference or endorsement. The constitutional mandate of separation aims to prevent fusion of governmental and religious functions, not to foster hostility toward religion. The state must maintain neutrality, but this neutrality is not absolute; it can accommodate religion when it does not involve coercion or prove detrimental to the state.
The Court found the use of the basement for religious activities was incidental and temporary, not a permanent dedication of public space to a sect. However, to prevent any violation, the Court laid down specific guidelines: religious activities must not interfere with official functions; attendance must be purely voluntary; no public funds must be spent directly for the activity; the area must remain accessible for secular purposes; and religious icons must be displayed only during the activity and concealed afterward. These guidelines apply to all halls of justice and extend equal accommodation to all religious groups. The ruling balances the constitutional prohibition against establishment with the equally vital principle of religious freedom and accommodation.